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Delhi High Court Dismisses Revenue's Demand Against Casio India In Transfer Pricing Case
Sahyaja MS
13 Oct 2025 3:15 PM IST
The Delhi High Court has recently dismissed a transfer pricing demand against Casio India, a wholly-owned subsidiary of the Japanese watchmaker, related to advertising, marketing and promotion expenses for the assessment year 2017-18The Division Bench of Justice V Kameswar Rao and Justice Vinod Kumar ruled that the issue had already been settled in Casio's favour in previous years and...
The Delhi High Court has recently dismissed a transfer pricing demand against Casio India, a wholly-owned subsidiary of the Japanese watchmaker, related to advertising, marketing and promotion expenses for the assessment year 2017-18
The Division Bench of Justice V Kameswar Rao and Justice Vinod Kumar ruled that the issue had already been settled in Casio's favour in previous years and therefore requires similar treatment.
“In fact, our attention has also been drawn to a decision dated 12.09.2025 in ITAs 415/2025 and 416/2025 relating to the same assessee/respondent, whereby the Tribunal has decided three ITAs being ITAs 385/Del/2016, 341/Del/2017 and 6733/Del/2017 relating to the AYs 2011-12, 2012-13 and 2013-14 and this Court by relying upon the order passed in Pr. Commissioner of Income Tax-1 v. Casio India Company Pvt. Ltd, ITA 211/2022 has dismissed the appeals filed by the appellant/revenue. For parity of reasons as given by this Court in ITA 211/2022, which we have reproduced above, the present appeal is also dismissed as no substantial question of law arises for consideration,” the court said.
The case concerned adjustments made by the Transfer Pricing Officer on the grounds that Casio India had incurred AMP expenses that benefitted its foreign Associated Enterprise. The Assessing Officer applied the Bright Line Test to compute an upward adjustment, which was later deleted by the Income Tax Appellate Tribunal (ITAT) in its order dated July 19, 2022.
The Revenue argued that the expenses amounted to an international transaction and should be benchmarked. It also cited two earlier appeals involving Casio India for AYs 2011-12 and 2015-16, in which similar issues had been admitted by the High Court for consideration.
However, the High Court rejected the Revenue's position, citing binding precedent in Casio's own case for AY 2014-15. The appeal was subsequently dismissed
Case Name: PR. COMMISSIONER OF INCOME TAX-1 v CASIO INDIA COMPANY PVT. LTD
Case Number: ITA 505/2025
Appearances:
For Appellant: Advocates Sanjay Kumar, Monica Benjamin, Easha (Standing Counsels for Revenue)
For Respondent: Advocates Kamal Sawhney, Puru Medhira
Click here to read/download order